Case 1:17-cv-05439 Document 1 Filed 07/25/17 Page 1 of 14 PageID: 1

Zainab K. Ali
Ali Law, PC
1601 Cherry Street, Suite 1320
Philadelphia, PA 19103
(267) 689-8481
zainab@alilawpc.com
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
______________________________________________
:
Keith Errol Benson, The Camden High School :
Alumni Association of Camden, NJ A NJ Nonprofit :
Corporation, Camden High School PTO LTD, :
MoNeke Ragsdale, Leslie Proctor, Frank M. Ingram, : Civil Action No.: 1:17-CV-5439
Namibia El and Doris Carpenter :
: Hon. ______________________
Plaintiffs, :
:
v. : COMPLAINT FOR DECLARATORY
: AND INJUNCTIVE RELIEF
New Jersey Schools Development Authority, :
Charles McKenna, Executive Director, New :
Jersey Schools Development Authority, :
Camden City School District; Camden City Board of :
Education, Paymon Rouhanifard, Superintendent :
Camden City School District :
:
Defendants. :
______________________________________________________________________________
______________________________________________________________________________

I. INTRODUCTION

1. Plaintiffs Keith Errol Benson, 1464 Belleview Avenue, Camden, New Jersey

08103, the Camden High School Alumni Association of Camden, NJ A NJ Nonprofit

Corporation (Hereinafter Camden High Alumni Association), 1775 Park Boulevard, Camden,

New Jersey 08103, the Camden High School PTO LTD, 317 Clinton Street, Camden. New

Jersey 08103, MoNeke Ragsdale, 317 Clinton Street, Camden, New Jersey 08103, Leslie

Procter, 2836 Idaho Road, Camden, New Jersey 08104, Frank Ingram, 969 North 35th Street,

Camden, New Jersey 08105, Namibia El, 1104 Carl Miller Boulevard, Camden, New Jersey
 Case 1:17-cv-05439 Document 1 Filed 07/25/17 Page 2 of 14 PageID: 2

08104, and Doris Carpenter, 1736 Hillcrest, Avenue, Pennsauken, New Jersey 08110,

(collectively referred to as Plaintiffs) bring this action against Defendants New Jersey School

Development Authority, 1 West State Street in the City of Trenton, County of Mercer, State of

New Jersey 08608, Charles McKenna, the Executive Director of the New Jersey School

Development Authority, 1 West State Street in the City of Trenton, County of Mercer, State of

New Jersey 08608, Camden City School District, 201 Front Street, Camden, New Jersey 08102,

Camden City Board of Education, 201 Front Street, Camden, New Jersey 08102, and Paymon

Rouhanifard, the state-appointed Superintendent of the Camden City School District, 201 Front

Street, Camden, New Jersey 08102.

2. Plaintiffs seek a declaratory order that the actions of the Defendants are unlawful

and invalid, and seek injunctive relief barring Defendants from contracting for, commencing,

allowing, permitting, advancing funds, for, or continuing demolition of the historic Camden High

School unless and until such time as Plaintiffs have had meaningful opportunity to participate.

3. Plaintiffs and other preservation organizations have repeatedly urged Defendants

to refrain from demolishing the historic Camden High School until such time as there has been a

fair and meaningful opportunity to be heard.

4. By hastily proceeding with demolition of the historic Camden High School

without releasing to the public any environmental impact studies, reports, plans, definitive or

otherwise, for the demolition or construction of the replacement school, Defendants sole purpose

is to evade public scrutiny and meaningful participation in violation of the Due Process Clause of

the Fourteenth Amendment of the United States Constitution, as well as New Jersey statutory law.

II. JURISDICTION AND VENUE

5. Plaintiffs allege deprivation of rights secure by the Due Process Clause of the

Fourteenth Amendment as protected by 42 U.S.C. 1983, and 42 U.S.C. 1988. Jurisdiction is

invoked pursuant to 28 U.S.C. 1331 and 1343.

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6. Venue is proper in this judicial district pursuant to 28 U.S.C. 1391(b) on the

grounds that Plaintiffs causes of actions arose in the District of New Jersey, some or all of the

conduct at issue took place in, and all the Defendants are found in the District of New Jersey.

III. PARTIES

7. Plaintiff Keith Errol Benson is an individual and Alumnus of Camden High

School with interest in the preservation of the history of and culture of Camden High School and

in the preservation of the environmental safety of the immediate surrounding areas. He has

strong interest in the preservation and re-use of the historic Camden High School, which is slated

for demolition as result of the actions complained of herein. His address is 1464 Belleview

Avenue, Camden, New Jersey 08103.

8. Plaintiff Camden High Alumni Association is an organization with seven or more

members and the capacity to sue and be sued in its own name. The non-profit corporation is

composed of alumni of Camden High School with interest in the preservation of the history of

and culture of Camden High School and in the preservation of the environmental safety of the

immediate surrounding areas. It has strong interest in the preservation and re-use of the historic

Camden High School, which is slated for demolition as result of the actions complained of

herein. Its mailing address is 1775 Park Boulevard, Camden, New Jersey 08103.

9. Plaintiff Camden High School PTO LTD is an organization with seven or more

members and the capacity to sue and be sued in its own name. Its membership includes current

and past parents and teachers of Camden High School students. It has strong interest in the

preservation and re-use of the historic Camden High School, which is slated for demolition as

result of the actions complained of herein. Its mailing address is 317 Clinton Street, Camden,

New Jersey 08103.

10. Plaintiff MoNeke Ragsdale is an individual and Alumnus of Camden High

School with interest in the preservation of the history of and culture of Camden High School and
 Case 1:17-cv-05439 Document 1 Filed 07/25/17 Page 4 of 14 PageID: 4

in the preservation of the environmental safety of the immediate surrounding areas. She has

strong interest in the preservation and re-use of the historic Camden High School, which is slated

for demolition as result of the actions complained of herein. Her address is 317 Clinton Street,

Camden, New Jersey 08103.

11. Plaintiff Leslie Procter is an individual with interest in the preservation of the

history of and culture of Camden High School and in the preservation of the environmental

safety of the immediate surrounding areas. She has strong interest in the preservation and re-use

of the historic Camden High School, which is slated for demolition as result of the actions

complained of herein. Her address is 2836 Idaho Road, Camden, New Jersey 08104.

12. Plaintiff Frank Ingram is an individual with interest in the preservation of the

history of and culture of Camden High School and in the preservation of the environmental

safety of the immediate surrounding areas. He has strong interest in the preservation and re-use

of the historic Camden High School, which is slated for demolition as result of the actions

complained of herein. His address is 969 North 35th Street, Camden, New Jersey 08105.

13. Plaintiff Namibia El is an individual with interest in the preservation of the

history of and culture of Camden High School and in the preservation of the environmental

safety of the immediate surrounding areas. Plaintiff Namiba El is a former Camden public

school teacher who worked in Camden High School from 1996 through 1998. She currently

provides educational and social supportive services to a number of Camden High School

students. She has strong interest in the preservation and re-use of the historic Camden High

School, which is slated for demolition as result of the actions complained of herein. Her address

is 1104 Carl Miller Boulevard, Camden, New Jersey 08104.

14. Plaintiff Doris Carpenter is an individual and Alumnus of Camden High School

with interest in the preservation of the history of and culture of Camden High School and in the

preservation of the environmental safety of the immediate surrounding areas. She has strong
 Case 1:17-cv-05439 Document 1 Filed 07/25/17 Page 5 of 14 PageID: 5

interest in the preservation and re-use of the historic Camden High School, which is slated for

demolition as result of the actions complained of herein. Her address is 1736 Hillcrest, Avenue,

Pennsauken, New Jersey 08110.

15. The Plaintiffs frequently use, enjoy, appreciate, and rely on the historic Camden

High School. The interest of Plaintiffs in preserving and protecting the historic Camden High

School will be harmed by the proposed action. Plaintiffs and its members are citizens and

taxpayers of the City of Camden and Camden County. The interests of Plaintiffs are prudent

public stewardship of the historic Camden High School building and successful future

development of the land surrounding the historic Camden High School.

16. The Plaintiffs have been actively involved in vigorous administrative advocacy,

education, and community organizing to secure adequate consideration of alternatives to

complete demolition of the historic Camden High School that would meet the purported goal of

providing a quality high school for the City of Camden.

17. Given their interests in and advocacy on behalf of protecting the historic Camden

High School, Plaintiffs have a strong interest in ensuring procedural due process and a

meaningful opportunity to be heard. Plaintiffs have suffered and will continue to suffer injury in

fact due to Defendants current and prospective action, unless the relief sought here is granted.

18. Defendant New Jersey School Development Authority (hereinafter NJ SDA) is

a New Jersey state entity established in, but not of, the Department of the Treasury with powers

and responsibilities to implement the Education Facilities Construction and Financing Act:

N.J.S.A. 18A: 17g-1. Its address is 1 West State Street in the City of Trenton, County of Mercer,

State of New Jersey 08608.

19. Defendant Charles McKenna is the Executive Director of the New Jersey School

Development Authority, and all times relevant hereto, exercises under the authority or color of

state law, to implement the Education Facilities Construction and Financing Act. His business
 Case 1:17-cv-05439 Document 1 Filed 07/25/17 Page 6 of 14 PageID: 6

address is 1 West State Street in the City of Trenton, County of Mercer, State of New Jersey

08608.

20. Defendant Camden City School District is a state governmental entity, capable of

suing or being sued in its own name, and all times relevant hereto, had the responsibility of direct

oversight of Camden High School. Its address is 201 Front Street, Camden, New Jersey 08102.

21. Defendant Camden City Board of Education is a state governmental entity,

capable of suing or being sued in its own name, and all times relevant hereto, has been operating

as an advisory board of education for Camden High School and in the City of Camden. Its

address is 201 Front Street, Camden, New Jersey 08102.

22. Defendant Paymon Rauhanifard is the state-appointed Superintendent of the

Camden City School District, and all times relevant hereto, exercises under the authority or color

of state law, substantial administrative and operational control over the Camden High School and

the Camden City School District. His business address is 201 Front Street, Camden, New Jersey

08102.

IV. GENERAL ALLEGATIONS

23. The historic Camden City High School is located at 1700 Park Boulevard at its

intersection with Baird Boulevard in the Parkside neighborhood in Camden, New Jersey 08105.

24. The historic Camden City High School was built in 1916 to the plans of architect

Paul Armon Davis, AIA (1872-1948) in the Gothic Revival style.

25. Subsequently, one additional building was added, The Annex, which includes the

gymnasium, to meet the growing demands of the high school. The Annex is the middle building

and the interconnecting pod buildings at the rear (north-northeast) of the building. These three

buildings are connected by two-story enclosed walkways.

 Case 1:17-cv-05439 Document 1 Filed 07/25/17 Page 7 of 14 PageID: 7

26. The historic Camden High School is well known as The Castle on the Hill and

is a point of cultural identity and pride for alumni, students, their parents, and the residents of the

City of Camden.

27. The historic Camden High School is located in a residential neighborhood and is

directly adjacent to homes, parks, a senior center, daycare and federally and state funded parks.

28. In 1996, the historic Camden High School was determined eligible for the New

Jersey Register as part of the Historic Parkside District.

29. In 2008, Governor Jon Corzine and the State of New Jersey Legislature approved

$100 million to revitalize Camden High School.

30. In 2009 the NJ SDA spent close to $4 million to restore the 75-foot tower and

leaded-glass windows.

31. In 2011, Governor Chris Christie axed the $100 million initially approved by his

predecessor for the revitalization of Camden High School.

32. In 2014, the Governor Chris Christie announced $50 million to fund Camden

High School upgrades. The money for the renovation was to come out of funding already

authorized by the Legislature under Governor Corzine.

33. However, on September 26, 2016, Camden Mayor Dana Reed and Superintendent

Paymon Rouhanifard held a meeting to inform a select group of residents about a new plan to

demolish, rather than restore the school.

34. Eight days later, on or around October 4, 2016, the New Jersey Schools

Development Authoritys Board of Directors approved a preliminary project charter allocating

$133 million of state bonded funds for construction of a new school.

35. Four hours later, Governor Christie appeared at the historic Camden High School

to celebrate the NJ SDA decision.

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36. On or about October 18, 2016, at an Advisory Board meeting, Superintendent

Paymon Rouhanifard publicly acknowledged that there was "more we could have done" to reach

out to the community.

37. It was announced in a press release that the School District would form three

community-led committees to participate in the project.

38. The aforementioned committees were formed by Mayor Dana Redd,

Superintendent Paymon Rouihanifard and Board President Martha Wilson.

39. Rather than provide an opportunity to participate, these committees served as a

rubber stamp for Defendants predesigned plans to demolish the historic Camden High School.

40. Participants who voiced concerns or who were in opposition to the direction of

Superintendent Paymon Rouihanifard and Board President Martha Wilson were simply ignored.

41. In January of 2017, the high school received a Certification of Eligibility from

the New Jersey Historic Preservation Office and was noted to be among the most architecturally

distinguished early twentieth century school buildings in the state.

42. On or about May 18, 2017, Theo Spencer, a former Camden School Board

Member and Mayoral candidate, expressed his concerns about the school being demolished, and

the potential removal of funds to construct a suitable replacement facility.

43. The replacement for the historic Camden High School is projected to be

completed in 2020. However, Plaintiffs are doubtful that any replacement will ever be

completed.

44. Kristen MacLean of the NJ SDA announced in response to Theo Spencers

concerns that funding for the project remains in place as the project is to be funded by bonded

dollars.

45. However, when a new Governor takes office she or he could elect not to fulfill the

project, just as Governor Chris Christie did when he eliminated the project for restoration four
 Case 1:17-cv-05439 Document 1 Filed 07/25/17 Page 9 of 14 PageID: 9

years ago, reopened it with half of the promised funding, then scrapped plans to restore the

school in favor of a costlier plan to completely demolish it in the final months of his tenure as

governor.

46. The students of Camden High School will be displaced during the demolition and

new construction. The period will be at least four years.

47. There is currently no disclosure of concrete plans for the instructional program of

the displaced students during the four-year period. There has been no community participation in

determining how this requirement of a thorough and efficient 21st century education will be

met. Partial justification to demolish the school is based upon the proposed changes needed to

the instructional program, but have never been disclosed or discussed in detail with the parents

and community.

48. In 2017, the Preservation New Jersey named Camden High School to its list of

the 10 Most Endangered sites of architectural and historical significance in the state.

49. The School is currently slated for complete demolition of all its structures.

50. However, demolition of the Annex, which includes the gymnasium and the

interconnecting pod buildings at the rear (north-northeast) of the building, will not have an

adverse effect on the historic main high school building, allowing more funding to be directed to

the preservation of the main building.

51. The two facades on Park and Baird Boulevards are in the best conditions, along

with the interiors spaces of the main entry, front hallway, and auditorium. The other interior

spaces retain little historic character, with the exception of surviving original doors and evidence

of original detailing in areas of little traffic. On the exterior, the two elevations with northern

exposures (the rear and northwest side elevations) are in worse condition and have less

visual prominence. If it is not financially feasible to retain the entire main building, it is

recommended that as large a portion of it as possible be kept intact, with new construction
 Case 1:17-cv-05439 Document 1 Filed 07/25/17 Page 10 of 14 PageID: 10

behind it on the site. In that way, both the beauty of the original architecture and the

innovations of the 21st century can combine to provide a stimulating learning environment

where the articulation of the historic architecture can combine with the technological

possibilities of the immediate future.

V. INJUNCTIVE RELIEF ALLEGATIONS

52. Plaintiffs incorporate and reallege each and every allegation contained in the

preceding paragraphs of this complaint.

53. On June 23, 2017, the NJ SDA hosted a mandatory pre-bid conference at Camden

High School, 1700 Park Boulevard, Camden New, Jersey 08103.

54. An Information Package, containing the requirements for the demolition

expressed in drawings, plans, Procedural and Performance Specifications, and other documents,

were to be made available through a controlled-access website to NJ SDA prequalified firms that

have attended the June 23, 2017 pre-bid conference.

55. On June 30, 2017, all bidders were required to complete a Project Rating Proposal

form and submit the complete PRP to the NJ SDA.

56. Bids are to be received by the NJ SDA until July 25, 2017, at which time bids are

to be publicly opened.

57. On Friday afternoon, July 7, 2017, the NJ SDA or its agents began the demolition

of Camden High School. Specifically, in the late afternoon, agents of the NJ SDA began

dismantling the Cafeteria and disposing of fixtures and presently continue demolition.

58. Defendants have begun demolition of Camden High School without regard to the

safety and environmental wellbeing of the community. Specifically, Defendants have begun

deconstruction of Camden High Schools weight room, cafeteria, and gymnasium.

59. Defendants destruction of Camden High School, by actors not authorized by law,

and before the completion of bidding, puts the Plaintiffs and the surrounding community at risk,
 Case 1:17-cv-05439 Document 1 Filed 07/25/17 Page 11 of 14 PageID: 11

and is an immediate threat to health, wellbeing, and the environment in violation of the Spill

Compensation and Control Act, N.J.S.A. 58:10-23.11, et seq.

60. Due to Defendants actions, Plaintiffs and other similarly situated, are and will

continue to be exposed to immediate unknown and unmitigated environmental dangers,

including but not limited to asbestos, in violation of the Spill Compensation and Control Act,

N.J.S.A. 58:10-23.11, et seq.

61. Due to Defendants actions, Plaintiffs and other similarly situated, are and will

continue to be denied the right to enjoyment of property, namely access and enjoyment to the

history and culture of the historic Camden High School.

62. Due to Defendants action, Plaintiffs and other similarly situated, are and will

continue to be denied their right to meaningful participation in matters to be held to a public

vote.

63. Specifically, there is pending litigation before the Supreme Court of New Jersey

alleging denial of the substantive statutory right to vote on whether the Camden Board of

Education should be elected or appointed in violation of New Jersey Civil Right Act.

64. If it is found that the Defendants have failed, neglected, and refused, to comply

with their ministerial duties or discretionary functions, said Defendants would accordingly not

have authority to order the destruction of Camden High School.

65. If not enjoined by this Court, Defendants and their agents, representatives, and

employees will continue to demolish the school, and implement similar policies and practices,

that deny Plaintiffs their Constitution rights without due process and deprive Plaintiffs of their

rights. This course of conduct will cause Plaintiffs to suffer irreparable injury, including but to

limited to loss of safety, history and culture. Plaintiffs have no plain, speedy, and adequate

remedy at law for such injury.

 Case 1:17-cv-05439 Document 1 Filed 07/25/17 Page 12 of 14 PageID: 12

66. Accordingly, injunctive relief pursuant to 42 U.S.C. 1983 and other authority is

appropriate.

VI. DECLARATORY RELIEF ALLEGATIONS

67. Plaintiffs incorporate and reallege each and every allegation contained in the

preceding paragraphs of this complaint.

68. An actual and substantial controversy exists between Plaintiffs and Defendants as

to their respective legal rights and duties. Plaintiffs contend that both on their face and as applied

to Plaintiffs, the challenged laws violate the Due Process Clause of the Fourteenth Amendment

and 42 USC. 1983. Plaintiffs also allege that Due to Defendants actions, Plaintiffs and other

similarly situated, are and will continue to be exposed to immediate unknown and unmitigated

environmental dangers, including but not limited to asbestos, in violation of the Spill

Compensation and Control Act, N.J.S.A. 58:10-23.11, et seq.

69. Plaintiffs are informed and believe, and on that basis allege, that Defendants

believe that their actions comply with all applicable laws.

70. Accordingly, declaratory relief pursuant to 28 U.S.C. 2201 is appropriate.

FIRST CLAIM FOR RELIEF ALL DEFENDANTS

(DUE PROCESS OF LAW, U.S. CONST. AMEND XIV & 42 U.S.C. 1983)

71. Plaintiffs incorporates and reallege each and every allegation contained in the

preceding paragraphs of this Complaint.

72. The committee established by the Defendants under Educational Facilities

Construction and Financing Act, N.J.S.A. 18A:7G-1, et seq. do not bear any relationship to

protecting the public health, safety, or welfare.

73. By enforcing the arbitrary, irrational, and fundamentally unfair procedure

established, Defendants acting under color of state law, are depriving and will continue to

deprive Plaintiffs of their constitutional rights.

 Case 1:17-cv-05439 Document 1 Filed 07/25/17 Page 13 of 14 PageID: 13

74. Plaintiffs are informed and believe, and on that basis allege, that Defendants

believe that their actions comply with all applicable laws.

75. An actual controversy exists between the parties, and Plaintiffs will continue to

suffer an ongoing and irreparable harm unless such action is declared unlawful and enjoined by

this Court.

SECOND CLAIM FOR RELIEF- ALL DEFENDANTS

(DUE PROCESS OF LAW: UNBRIDLED DISCRETION OF PUBLIC OFFICIALS,
U.S. CONST. AMEND. XIV & 42 U.S.C. 1983)

76. Plaintiffs incorporate and reallege each and every allegation contained in the

preceding paragraphs of this Complaint.

77. The regulations and procedures Defendants have adopted to enforce the

Educational Facilities Construction and Financing Act, N.J.S.A. 18A:7G-1, et seq. grant

Defendants and their staff unlimited and unguided discretion.

78. The defendants, acting under color of state law, grant the NJ SDA staff unbridled

discretion to impose their will on the selected committees through broadly authorized authority,

without a meaningfully opportunity to be heard.

79. By exercising unlimited, unguided discretion over the process, Defendants, acting

under color of state law, violate Plaintiffs right to equal due process of law as guaranteed by the

Fourteen Amendment of the United States Constitution and 42 U.S.C 1983.

80. Plaintiffs are informed and believe, and on that basis, alleges that Defendants

believe that their actions comply with all applicable laws.

81. An actual controversy exists between the parties, and Plaintiffs are suffering an

ongoing and irreparable harm by Defendants discriminatory treatment, and the harm will

continue unless declared unlawful and enjoined by this Court.

 Case 1:17-cv-05439 Document 1 Filed 07/25/17 Page 14 of 14 PageID: 14

VII. RELIEF REQUESTED

WHEREFORE, Plaintiffs respectfully requests this Court grant the following relief:

1. Declare the Defendants and their employees, grantees, agents, and contractors to

comply fully with the requirements of the due process clause of the Fourteenth Amendment prior

to any further planning, financing, contracting, or demolition of the historic Camden High

School.

2. Issue temporary, preliminary, and permanent injunctive relief directing all

Defendants and their grantees, employees, agents, and contractors, to refrain from any further

planning, financing, contracting, or demolition of the historic Camden High School until it has

complied with due process which includes, but is not limited to approval by the New Jersey

Department of Environmental Protection.

3. Issue temporary, preliminary and permeant injunctive relief, prohibiting the NJ

SDA or any Defendant from demolishing the historic Camden High School until it has complied

with due process.

4. Award Plaintiff its attorneys fees, costs, and disbursements; and

5. Award such other and further relief as the Court may deem appropriate.

Respectfully submitted,
By: ___________________________
/s/Zainab K. Ali
Ali Law, PC
1601 Cherry Street, Suite 1320
Philadelphia, PA 19103
(267) 689-8481
zainab@alilawpc.com

CERTIFICATION

I hereby certify that the matter in controversy is not the subject of any other court,

arbitration or administrative proceeding.

By: ___________________________
/s/Zainab K. Ali
 Case 1:17-cv-05439 Document 1-1 Filed 07/25/17 Page 1 of 1 PageID: 15
JS 44 (Rev. 06/17) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

Keith Errol Benson, et. al. New Jersey School Development Authority, et. al

(b) County of Residence of First Listed Plaintiff Camden County of Residence of First Listed Defendant Mercer
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

Zainab Khadija Ali, Ali Law PC, 1601 Cherry Street, Suite 1320,
Philadelphia, PA 19102, Tel: 267-689-8481

II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an X in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation
Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY 480 Consumer Credit
of Veterans Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards 861 HIA (1395ff) 490 Cable/Sat TV
160 Stockholders Suits 355 Motor Vehicle 371 Truth in Lending Act 862 Black Lung (923) 850 Securities/Commodities/
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management 863 DIWC/DIWW (405(g)) Exchange
195 Contract Product Liability 360 Other Personal Property Damage Relations 864 SSID Title XVI 890 Other Statutory Actions
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 865 RSI (405(g)) 891 Agricultural Acts
362 Personal Injury - Product Liability 751 Family and Medical 893 Environmental Matters
Medical Malpractice Leave Act 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation FEDERAL TAX SUITS Act
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 870 Taxes (U.S. Plaintiff 896 Arbitration
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act or Defendant) 899 Administrative Procedure
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 871 IRSThird Party Act/Review or Appeal of
240 Torts to Land 443 Housing/ Sentence 26 USC 7609 Agency Decision
245 Tort Product Liability Accommodations 530 General 950 Constitutionality of
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION State Statutes
Employment Other: 462 Naturalization Application
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration
Other 550 Civil Rights Actions
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an X in One Box Only)
1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
42 U.S.C. Section 1983 and 28 U.S.C. Section 2201
VI. CAUSE OF ACTION Brief description of cause:

VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
July 25, 2017 /s/zainab K. Ali
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE